How have the courts interpreted the definition of "lascivious touching" in the context of sexual assault charges?

"Here, the trial court failed to instruct the jury that an essential element of the crime charged was that the defendant's touching of the victims had to be lewd and lascivious, regardless of his specific intent. Further, the prosecutor misled the jury by arguing that 'any' touching, however innocuous, such as brushing a child's hair or touching a child's arm with the requisite specific intent would satisfy the statute. Finally, the film showed many instances of touching of the victims' bodies by the defendant that were not lewd in nature but which the jury could have found to be lewd under the instruction given." (People v. Wallace, supra, 11 Cal.App.4th 568, 580, 14 Cal.Rptr.2d 67.)